United States: FATCA Primer For Non-Financial Enterprises

The Foreign Account Tax Compliance Act (FATCA) added a new chapter 4 (sections 1471–1474) to the Internal Revenue Code and Treasury Regulations thereunder.  While foreign financial institutions (FFIs) have the most substantial compliance burden under FATCA, the new law also affects non-financial foreign entities (NFFEs).  The compliance burden on NFFEs is less onerous than the compliance obligations of FFIs, but failure to comply could result in a 30 percent withholding tax on certain U.S.-source […]

By |November 12th, 2014|

United States: REIT Spin-Offs: Recent Transactions And IRS Rulings

Several recent corporate spin-offs in the United States have involved real estate investment trusts (REITs).  Provided several requirements are satisfied, including qualification of the “spun-off” entity as a REIT and the spin transaction as a tax-free spin-off, REIT spin-offs can result in significant value to shareholders.  In these transactions, a corporation distributes a subsidiary corporation holding real estate to the distributing corporation’s shareholders in a tax-free spin-off.  Not only is the spin-off tax-free, but […]

By |November 12th, 2014|

Turkey: Taxation, Import, Export And Transfers Under Turkish Petroleum Law

The Turkish Petroleum Law, a touchstone for goals of attracting foreign investors to Turkish petroleum industry entered into force on 11 June 2013 and has been introduced as a revolution in oil and gas industry as it was leveling the playing field for foreign investors and removing the privileged rights of the state company.

However the expectations in taxation of income remain unchanged contrary to the expectations during the draft law and the sum of […]

By |November 12th, 2014|